Legal Opinion

Thompson v. Commissioner

United States Tax Court

Decided May 21, 1952No. Docket Nos. 25005, 25006PublishedCited by 1 opinion

Depreciation or "amortization" deductions may not be taken by partnership with respect to alleged basis of certain war contracts performed by it.

1Opinion of the Court

OPINION.

Raum, Judge:

Petitioner Couse owned 95 per cent of the stock of Couse Laboratories, Inc., and dominated its affairs. At the time of its dissolution on October 31,1942, it had uncompleted contracts calling for the production and delivery of war goods for an aggregate price of $8,416,746.13. Petitioner Couse had designed and developed the mobile machine shops and signal towers which were the subject matter of the contracts, and these contracts had been awarded to the corporation originally by reason of the know-how possessed by petitioner Couse, in whom the War Department had confidence.…

2Cases cited3 opinions

  1. United States Industrial Alcohol Co. v. HelveringCourt of Appeals for the Second Circuit · 1943
  2. Francis v. United StatesSupreme Court of the United States · 1878
  3. Francis ex rel. Myrick v. United StatesSupreme Court of the United States · 1875

3Cited by1 opinion

  1. Thompson v. CommissionerUnited States Tax Court · 1952

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